Regulatory Update

EU EUDAMED mandatory modules official May 2026 timeline confirmed

The EU EUDAMED mandatory modules 2026 requirement comes from Decision (EU) 2025/2371, which confirms four modules—Actor Registration, UDI/Devices, Notified Bodies & Certificates, and Market Surveillance—are fully functional. From 28 May 2026, manufacturers must register new MDR/IVDR devices before placing them on the EU market, while legacy devices must be registered by 28 November 2026. Certificates issued before that date must be uploaded by 28 May 2027.

Published on:
December 2, 2025

The EU EUDAMED mandatory modules 2026 timeline has been officially confirmed through Decision (EU) 2025/2371, published on 27 November 2025. The European Commission declared the first four EUDAMED modules fully functional, activating the six-month transition period foreseen in Regulation (EU) 2024/1860. This milestone marks a major step in strengthening EU medical device transparency under the MDR and IVDR, bringing new obligations for manufacturers, authorised representatives, and importers.

Key Updates in Decision (EU) 2025/2371

The publication confirms that the first four EUDAMED modules now meet the functional requirements of Article 34(2) MDR. As a result, their use becomes mandatory from 28 May 2026, ending years of voluntary operation. This change aims to enhance traceability, market oversight, and regulatory consistency across the EU medical device ecosystem.

Which EUDAMED Modules Become Mandatory on 28 May 2026

From this date, all responsible economic operators under MDR/IVDR must use the following four modules:

  • Actor Registration
  • UDI/Devices Registration
  • Notified Bodies & Certificates
  • Market Surveillance

These modules form the core regulatory data flows required for device traceability and oversight.

Deadlines for New, Legacy, and Certified Devices

  • New MDR/IVDR devices: Must be registered in EUDAMED before market placement starting 28 May 2026.
  • Legacy devices and devices placed on the market before 28 May 2026: Must be registered by 28 November 2026.
  • Certificates issued before 28 May 2026: Must be uploaded by 28 May 2027.
    These deadlines align with the transitional provisions set in Regulation (EU) 2024/1860.

Impact on Economic Operators

Manufacturers, authorised representatives, and importers must ensure internal readiness. Without an SRN through the Actor Registration module, other submissions—including UDI/Device data—cannot proceed. Notified bodies must prepare certificate datasets to avoid delays, and competent authorities will shift to systematic use of the Market Surveillance module.

How to Prepare for the 2026 EUDAMED Requirements

  • Validate your actor profiles and ensure SRN accuracy.
  • Perform a UDI/DI gap assessment for MDR, IVDR, and legacy devices.
  • Prepare for bulk uploads or configure machine-to-machine (M2M) communication.
  • Coordinate with notified bodies for timely upload of MDR/IVDR certificates.
  • Review your EU market portfolio to prioritise devices with tight transition timelines.

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